ML20247E558
| ML20247E558 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/11/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-98-03, 70-7001-98-3, NUDOCS 9805180382 | |
| Download: ML20247E558 (1) | |
Text
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s May 11, 1998 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
RESPONSE TO PADUCAH INSPECTION REPORT 70-7001/98003
Dear Mr. Miller:
This refers to your May 6,1998, response to the Notice of Violation (NOV) transmitted to you by our letter dated April 6,1998, with Inspection Report 70-7001/98003. We have reviewed your corrective actions and have no further questions at this time. Your corrective actions will be examined during future inspections, if you have any questions, please contact me at (630) 829-9603.
Sincerely, Original Signed by Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70-7001 cc:
S. A. Polston, Paducah General Manager L. L. Jackson, Paducah Regulatory Affairs Manager J. M. Brown, Portsmouth General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE bec w/itr dtd 05/06/98:
Docket File w/enci PUBLIC IE-07 w/enci R. Pierson, NMSS w/enci l
P. Ting, NMSS w/enci W. Schwink, NMSS w/enct P. Harich, NMSS w/enci j
M. Horn, NMSS w/enci
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R. Bellamy, RI w/ encl i N()C ]cj EJM, Ril w/o enci (e-mail)
F. Wenslawski, RIV/WFCO w/enci Greens w/o enc!
DOCUMENT NAME: G:\\SEC\\ PAD 98003.RES To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E" = Copy with enclosure *N" = No copy OFFICE Rlli l (; Rlli l f.
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NAME Kniceley:ib C/1 Hiland fl.\\M DATE 05A\\ /98 05/ ll/98 DO 00 01 C
USEC A Global Energy Company May 6,1998 GDP 98-1033 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Response to Inspection Report (IR) 70-7001/98003 Notice of Violation (NOV)
The subject IR contained one NOV conceming the failure to implement the requirements of USEC
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procedure UE2-TO-NS1032 for an inoperable UF. detection system. USEC's response to the j
violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this response. The i
corrective actions specified in the enclosures apply solely to PGDP.
Any questions regarding this matter should be directed to Larry Jackson at (502) 441-6796.
Sincerely, J
h Steve Polston General Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated i
cc:
NRC Region III Office NRC Resident Inspector - PGDP l
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l P.O. Box 1410, Paducah, KY 42001 MAY 11 W Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com O!Tices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
)-)5
GDP 98-1033 Page1of3 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98003-01 Restatement of the Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented for activities described in Appendix A, to Safety Analysis Report, Section 6.11.
Safety Analysis Report, Section 6.11, Appendix A, described administrative activities, including i
operations, as activities for which procedures shall be developed and implemented, i
Procedure UE2-TO-NS1032, " Operability Evaluations and Resolution of Degraded and Nonconforming Conditions," Revision 0, dated December 31,1996, required, in part, the plant shin
' superintendent to: 1) declare a structure system or component inoperable that is unable to fulfill an L
intended safety function; 2) implement the Technical Safety Requirement Action Statements; and,
- 3) make required regulatory reports in accordance with Procedure UE2-RA-RE1030, " Nuclear l
Regulatory Event Reporting."
Procedure UE2-RA-RE1030, " Nuclear Regulatory Event Reporting," Revision 2, dated October 31, 1997, required, in part, the plant shift superintendent to make a report to the NRC, within 24-hours, for an event in which equipment that is disabled, is required by the Technical Safety Requirements L
to mitigate the consequences of an accident and no redundant is available and operable to perform the safety function.
i Technical Safety Requirement 2.2.4.1, requires the UF. release detection system, including local alarms, to be operable whenever the autoclaves are in Modes 4 or 5.
Contrary to the above, between March I and March 6,1998, the plant shift superintendent did not implement the requirements of Procedure UE2-TO-NS1032 for an inoperable UF detection system in Building C-333A with the autoclaves in Modes 4 or 5. Specifically, the plant shin superintendent did not: 1) declare the UF release detection system inoperable; 2) direct implementation of the Technical Safety Requirement Action Statements; and,3) make the required 24-hour report to the NRC for the disabled safety-related equipment.
USEC Response I.
Reason for the Violation The reason for this violation was that the Plant Shift Superintendent (PSS) made a determination on operability using information limited tojust the TSR basis statement. The
.e GDP 98-1033 Page 2 0f 3 Technical Safety Requirement 2.2.4.1, requires the UF release detection system to be 6
operable whenever the autoclaves are in Modes 4 or 5. The basis statement for this TSR states, "This system detects the presence of this ' smoke' and sounds an alarm to alert operating personnel to initiate corrective / mitigative action." The basis was not specific as to the alarm location required. The PSS determined a UF detector head would detect smoke 6
and would activate an alarm on the UF detector panel in the Operations Monitoring Room 6
(OMR). An operator was stationed in the OMR to monitor the alarm panel in order to alert others in the area of a release. The PSS did not consider this to be required by the TSR because the detectors and the OMR alarm were known to be functioning properly. Based on this, the PSS determined the TSR was met without review of the SAR requirements or any I
other plant documents. The erroneous operability determination resulted.
Contributing factors to this event were:
The basis statement for TSR 2.2.4.1,"UF6 Release Detection System -Autoclave Heated Housings, Piping Trench, Jet Station, West Wall Detectors (C-337-A Only)"
does not identify the specific alarms that are necessary for the UF release detection 6
system to be operable.
UE2-TO-NS1032, " Operability Evaluations and Resolution of Degraded and Nonconforming Conditions" does not contain sufficient guidance for the PSS on the plant procedures /documecds to be consulted when making operability decisions to ensure these decisions are made in a consistent manner.
Ill.
Corrective Action Taken and Results Achieved 1.
On March 6,1998, the UF release detection system was declared inoperable and the 6
required notification to NRC was completed.
2.
The PSS who made the error developed a lessons leamed package regarding the need to complete a review of relevant approved plant documents, such as the SAR, TSR and Boundary Designation Manual (BDM), for the operability decision made for the UF release detection system. Crew briefings on this package were provided to all 6
PSS/APSSs. This was completed on May 1,1998.
IV.
Corrective Actions to be Taken 1.
The Basis Statement for TSR 2.2.4.1 will be revised by July 24,1998, to identify those alarms necessary for the system to be operable.
i 1-GDP 98-1033-Page 3 of 3 2.
Procedure UE2-TO-NS1032 will be revised by August 30,1998, to provide better guidance to personnel when making operability determinations (e.g., reviewing applicable documents such as the TSR, SAR,'and Boundary Designation Manual (BDM), for the afTected system).
3.
This event will be included in the training modules for new PSSs. This action will l
be completed by June 30,1998.
V.
Date of Full Comoliance USEC achieved full compliance on March 6,1998, when the UF release detection system 6
was declared inoperable and the required notification to NRC was completed.
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GDP 98-1033 Page1of1 LIST OF COMMITMENTS 1.
The Basis Statement for TSR 2.2.4.1 will be revised by July 24,1998, to identify those alarms necessary for the system to be operable.
2.
Procedure UE2-TO-NS1032 will be revised by August 30,1998, to provide better guidance to personnel when making operability determinations (e.g., reviewing applicable documents such as the TSR, SAR, and Boundary Designation Manual (BDM), for the affected system).
3.
This event will be included in the training modules for new PSSs. This action will be completed by June 30,1998.
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